State Agency Specific Questions:

e-Manifest General Approach:

Will e-Manifest be like other shipment tracking systems that I’m familiar with?

E-Manifest will provide information to users indicating where the waste is in the shipping process
(i.e., ‘In Transit’, ‘Delivered’, etc.) after a manifest is signed. Conceptually, this type of shipment
tracking is very similar to other shipment tracking systems that report on the status when a package is scanned.
There are some distinct differences about hazardous waste manifests:

A hazardous waste manifest applies to an entire shipment, as opposed to individual packages

A hazardous waste manifest tracks additional information (different from other commercial shipment systems)
that are unique to the tracking of hazardous waste, and

Because manifests are required by 40 CFR, the electronic signatures used as part of the manifest process
must meet the EPA’s standards and requirements for ensuring legal defensibility of electronic signatures.
Currently, this standard is referred to as EPA’s Cross Media Electronic Reporting Rule (CROMERR).
CROMERR is unique to EPA, and EPA is evaluating options that will both meet the CROMERR requirements and
be acceptable to the user community.

Will e-Manifest be real-time so I can check on the status of a shipment?

EPA is evaluating technical options for the implementation of e-Manifest. At this time, the technical
capabilities of e-Manifest are not yet fully defined.

EPA does not envision providing the ability to track waste in real time; for example, users will not have
the ability to see the exact geographic location of a shipment at all times during the shipping process. If
information on the location of the waste becomes a requirement of the system, it is likely that EPA would only
track the location and shipping status at each interval where the manifest is signed. Users of the system will
be able to track this status of a shipment throughout the entire shipping process. EPA does not envision that
the shipment status would be available to the public until the shipment is received and accepted by the treatment,
storage, disposal facility (TSDF).

Will data be publicly available?

EPA envisions that the data in e-Manifest will be made publicly available once a shipment is accepted by a
TSDF and the data is verified. We recognize that hazardous waste shipments are live commercial transactions,
and that manifest access should be restricted during the time that a shipment is in process. From the comments
on the draft rule and other past notices, EPA recognizes that there may be some sensitivity about the aggregation
of data collected from manifests and how aggregate data might be used for competitive purposes. EPA will be
clarifying this issue in the ‘One Year Rule’ that is due to be published in October 2013.

EPA is conducting a requirements analysis that may explore approaches for making the data publicly available,
the timing for making thedata available, and meeting the needs of the stakeholders for data access.

Will the system include all manifests, or just those electronically submitted?

EPA envisions that the e-Manifest system would contain data from all manifests, including paper manifests.
The Hazardous Waste Electronic Manifest Establishment Act (The Act) includes authority for EPA to include,
via rulemaking, such requirements that may be necessary to facilitate the transition from paper to electronic
manifests, including accommodating the processing of data from paper manifests, and collecting reasonable service
fees to recover the costs of processing paper manifests. As EPA evaluates the fee structure for e-Manifest,
we will explore how to balance the cost of paper versus electronic manifests to ensure that EPA can recover the
costs of processing the paper manifests.

Will I still be able to use paper manifests?

The Act acknowledges that the use of electronic manifests is at the option of the users, and it calls for
EPA to facilitate the transition from paper to electronic manifests. EPA will continue to accept paper manifests
to accommodate this transition, and we will process the data from those manifests so that they are included in the
e-Manifest system. As EPA evaluates the fee structure for e-Manifest, we will explore how to balance the cost of
paper versus electronic manifests to ensure that EPA can recover the costs of processing the paper manifests.

How will e-Manifest accommodate non-RCRA wastes that require a manifest under state law?

Under the Act, the scope of the e-Manifest system extends to both Federal RCRA hazardous wastes and to
state-regulated wastes for which a manifest requirement is imposed under state law. Many states regulate
additional wastes as hazardous or special wastes under their state regulatory programs, and the states may
require shipments involving these non-RCRA wastes to be tracked with the hazardous waste manifest. To avoid
the need for a separate tracking system for state-regulated wastes, the Act authorizes EPA to establish the
national e-Manifest system to track the Federal RCRA and state-regulated wastes.

Will States be permitted to require different or additional electronic manifests?

No. The hazardous waste manifest is required to be a uniform shipping document under both RCRA and the
hazardous materials transportation laws. Since 2006, EPA has required the use of a Uniform Manifest form that
precludes state variations, other than tracking states’ additional wastes subject to the manifest, and entering
state waste codes and facility ID numbers that are not redundant with RCRA waste codes and ID numbers. The
electronic manifest will operate in the same manner, and EPA and the national e-Manifest system will support
only the uniform electronic manifest format that EPA will establish as the national standard once the e-Manifest
is implemented. States will be precluded from requiring different or additional formats or requirements.

e-Manifest System Planning and Implementation:

How will EPA determine what the system needs to do?

In February and March of 2013, EPA conducted a series of face-to-face system requirements
meetings. The purpose of the face-to-face meetings was to collect up-to-date requirements for e-Manifest’s
functionality and operations. Each meeting was a day and a half. Each meeting was similar in agenda,
providing multiple opportunities for stakeholder participation. EPA also conducted a series of webinars
throughout 2013 to better understand user needs. For more information on these face-to-face meetings, or
upcoming webinars see the e-manifest web site.

How do I get involved in e-Manifest system planning?

EPA recognizes that the stakeholders for e-Manifest are broad and diverse. EPA spent a
large part of FY 2013 meeting with stakeholders. EPA conducted face-to-face system requirements
gathering meetings (see past meetings) from February 2013-March 2013. EPA also conducted a series
of webinars throughout to solicit feedback and to get input on the system requirements and functionality. EPA
recognizes that the success of this project relies heavily on the buy-in of the user community. To get involved, please subscribe to the e-Manifest ListServ (at the very bottom of the e-Manifest page).

When does EPA expect the system to be online?

The Act calls for the system to be online three years from the signing of the Act. The Act was signed in
October 2012, which means that the system should be online by October 2015. EPA is taking action now to meet
the deadline. As with any Informational Technology (IT) project, there are significant unknowns that could
affect the delivery date. As more information becomes available, EPA will post project schedule information
on the e-Manifest web site.

How will e-Manifest impact the Biennial Report?

The Act defines one of the performance goals of the system to be: “…provides the waste receipt data
applicable to the biennial reports…” Through the implementation of e-Manifest, EPA will be evaluating how
best to implement this goal. It should be noted, however, that the waste receipt portion of the Biennial
Report (BR) is only one portion of the report (the ‘Waste Received From Off-Site’ or ‘WR’ form). EPA will
need to evaluate how best to incorporate information contained in the ‘Waste Generation and Management’ or
‘GM’ form. Information historically reported on the GM form for waste that is shipped off-site has the
potential to also be included in e-Manifest. Waste managed on-site likely could not be included as part
of e-Manifest, and would still need to be reported via the Biennial Report.

How will the Department Of Transportation (DOT) shipping paper requirements factor into e-Manifest?

Until DOT updates its regulations, a paper copy will still be required to meet DOT purposes. EPA is working
closely with DOT to ensure that the new e-Manifest system will continue to meet DOT needs, as well as the needs
of first responders.

e-Manifest Rulemaking:

Where can I find the legislation?

The Hazardous Waste Electronic Manifest Establishment Act was signed into law in October 2012. It is Senate Bill 710 (S 710) in the 112th Congress.

What new rules will be needed to implement e-Manifest?

EPA has completed the One Year Rule which authorizes electronic manifests. EPA however will need to establish the e-Manifest system and the initial fee structure for the use of e-Manifest. EPA envisions needing one more rule to implement e-Manifest. The next rule (ie, the Fee Rule) will establish the initial fee structure for e-Manifests and announce the actual implementation and compliance date for their use.

What is the ‘One Year Rule’ that I keep hearing about?

The One Year Rule is the rule that EPA promulgated in order to comply with the Hazardous Waste Electronic Manifest Establishment Act, which required EPA to issue a regulation authorizing electronic manifests by October 5, 2013. In issuing this rule, EPA completed an important step that must precede the development of a national e-Manifest system, as required by the Hazardous Waste Electronic Manifest Establishment Act. This rule simply codifies several of the essential provisions of the Act, provides the legal and policy framework to authorize use of electronic manifests, and amends the existing manifest regulations to announce policy on electronic signatures and access to information (CBI).

How will the fees be set?

The Act calls for EPA to set the initial fees via a rulemaking in consultation with IT vendor(s). This
rulemaking is envisioned to take place in 2014. The initial fees will be set to cover not only operation
and maintenance costs, but also the costs of developing the system. The Act also calls for the establishment
of a Hazardous Waste Electronic Manifest System Advisory Board that consists of at least two people with expertise
in information technology, three people with experience in using or representing users of the e-Manifest system, and
three State representatives. The Act calls for this board to be established no later than October 2015. EPA will
consult with this board to make adjustments to the fees once the board is established.

Industry-Specific Questions:

I’m a generator; what do I need to do to get ready for e-Manifest?

It is currently envisioned that a generator would see several benefits from e-manifest, including the ability
to fill out manifests online, using drop-downs and pre-populated forms. Generators would also be able to track
their shipments and receive confirmation on delivery and acceptance. E-Manifest would also help the generators
in meeting some of their recordkeeping requirements in relation to manifests.

Here are a number of key things that you can do as generators to make sure that you’re ready for e-Manifest:

Get Involved: In order to ensure that e-Manifest integrates into your business process, you
can start now by making sure that EPA understands your business process, including any data systems that you
currently use for tracking hazardous waste and for generating manifests. Participate in one of EPA’s system
requirements meetings or webinars either directly or through a trade association.

Talk to your transporters and TSDFs: Since e-Manifest integrates the tracking of manifests
across many parties, it is important that you communicate with your transporters and TSDFs to determine how
they intend to implement e-Manifest as EPA releases more information on the design of the system. In many cases,
the transporter will supply the technology with which generators will participate in e-Manifest.

Check the e-Manifest website regularly: New information will be posted to the
e-Manifest website as it becomes available. The best way to stay informed will be to
check the website regularly.

As more details on e-Manifest become available, this list will expand. Make sure you check back to see the
most current list of recommendations.

I’m a transporter; what do I need to do to get ready for e-Manifest?

EPA recognizes that transporters are a key client of the e-Manifest system. For example, it has always been
envisioned that e-Manifest would be able to support mobile devices, and these mobile devices will most often be
carried on transport vehicles so that the e-Manifest can provide cradle-to-grave tracking services. This is of
particular importance to the transporters. E-Manifest would eliminate the need for the current 6-page paper
manifest; however there may still be some minimal need to carry paper in order to support DOT requirements.

Here are a number of things you can do as transporters to make sure that you’re ready for e-Manifest:

Get Involved: In order to ensure that e-Manifest integrates into your business process,
you can start now by making sure that EPA understands your business process, including any data systems that
you currently use for tracking manifests. Participate in one of EPA’s system requirements meetings or webinars
either directly or through a trade association. You should pay particular attention to any discussion around
the electronic signature requirements for e-Manifest.

Talk to your generators and TSDFs: Since e-Manifest integrates the tracking of manifests
across many parties, it is important that you communicate with your generators and TSDFs to determine how they
intend to implement e-Manifest as EPA releases more information on the design of the system.

Check the e-Manifest website regularly: New information will be posted to the
e-Manifest website as it becomes available. The best way to stay informed will be to
check the website regularly.

As more details on e-Manifest become available, this list will expand. Make sure you check back to see the
most current list of recommendations.

I’m a treatment, storage, disposal facility (TSDF); what do I need to do to get ready
for e-Manifest?

EPA is seeking to learn as much as we can about the current business process that TSDFs use for providing
and tracking manifests. EPA views TSDFs as a key customer of the e-Manifest system.

Here are a number of things you can do as TSDFs to make sure that you’re ready for e-Manifest:

Get Involved: In order to ensure that e-Manifest integrates into your business process,
you can start now by making sure that EPA understands your business process, including any data systems that
you currently use for tracking manifests. Participate in one of EPA’s system requirements meetings or webinars
either directly or through a trade association.

Talk to your generators and transporters: Since e-Manifest integrates the tracking of
manifests across many parties, it is important that you communicate with your generators and transporters to
determine how they intend to implement e-Manifest as EPA releases more information on the design of the system.

Check the e-Manifest website regularly: New information will be posted to the
e-Manifest website as it becomes available. The best way to stay informed will be to
check the website regularly.

As more details on e-Manifest become available, this list will expand. Make sure you check back to see the
most current list of recommendations.

How will e-Manifest apply to hazardous waste shipments that move via rail?

The rail industry currently operates an electronic waybill system that enables rail shippers and carriers to track
the location and status of hazardous materials shipments that move on the rail system. While EPA’s primary focus in
developing e-Manifest is to facilitate the tracking of hazardous wastes that are shipped over the highway, the Agency,
through its requirements gathering process, plans to coordinate with the rail industry so as to reduce the burden that
the rail industry currently incurs in receiving paper manifests at rail offices, manually entering manifest data into
the waybill system, and forwarding the remaining manifest forms by mail to the next RCRA handler.

State Agency-Specific Questions:

I’m a state agency; what do I need to do to get ready for e-Manifest?

Several states require that paper hazardous waste manifests be delivered to the state at various stages in the
shipping process. For these states, e-Manifest will provide some significant improvements in the timelines, accuracy,
and efficiency of data collection. However, e-Manifest will also create some significant changes to how manifests are
delivered to the states. EPA is seeking to learn as much as we can about state requirements, including specific state
reporting requirements and Quality Assurance/Quality Control requirements. If you are a state that currently does not
collect manifests, EPA also values your input as to how e-Manifest may impact you in the future.

Here are a number of things you can do as states to make sure that you’re ready for e-Manifest:

Get Involved: In order to ensure that e-Manifest integrates into your business process, you can
start now by making sure that EPA understands your state reporting process, including any data systems that you
currently use for tracking manifests. Participate in one of EPA’s system requirements meetings or webinars.

Talk to your state IT staff: EPA envisions using the to provide manifest
information to the states. Currently all states have the ability to receive information via the Exchange Network,
but additional work will need to be done in order to receive specific manifest data, and to incorporate those data
into the state systems. If you are currently not familiar with the Exchange Network, EPA encourages you to visit the
Exchange Network Website
to not only learn more about the Exchange Network, but also to find out who in your state can provide
more information.

Check the e-Manifest website regularly New information will be posted to the
e-Manifest website as it becomes available. The best way to stay informed will be to check
the website regularly.

As more details on e-Manifest become available, this list will expand. Make sure you check back to see the most
current list of recommendations.

How are ASTSWMO (Association of State and Territorial Solid Waste Management Officials)or ECOS (Environmental
Council of the States) involved in e-Manifest?

EPA will continue to work with ASTSWMO and ECOS to inform and involve states in e-Manifest’s planning and
implementation. ASTSWMO and ECOS provide important avenues through which EPA can reach out to states on various
e-Manifest topics, ranging from technical system discussions to general programmatic impacts. Please continue to
visit the e-Manifest website for more information about outreach efforts through these avenues or others.

Will e-Manifest use the Exchange Network?

EPA will evaluate all technical options for implementing e-Manifest in 2013. EPA does expect that the
Exchange Network
will be used for EPA-to-state interactions.

How will e-Manifest impact RCRAInfo?

e-Manifest would be a separate system from RCRAInfo. With e-Manifest development and implementation over the next
three years, EPA does not see any immediate impact to the RCRAInfo system or its users. EPA’s planning and
requirements gathering efforts for e-Manifest will explore possible linkages between the e-Manifest system and
RCRAInfo, especially in identifying valid hazardous waste handler identifiers (the EPA ID from the Uniform Manifest
and the Site ID form) and providing valid look-up values (i.e., valid waste codes, units of measure, etc.).